Core Strategy Preferred Options (Revised October 2008)
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Core Strategy Preferred Options (Revised October 2008)
H1 Distribution - Preferred Option
Representation ID: 4292
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
We will prioritise the reuse of previously developed land identified as being appropriate, including as part of our SHLAA, having regard to the need to protect sites of ecological importance. Areas coming forward for residential development identified within the Urban Capacity Study will be required to conform to all policies within the Core Strategy, particularly in relation to infrastructure, and larger sites will be required to be comprehensively planned.
In order to protect the character of existing settlements, we will prioritise delivery of larger sites over intensification of smaller sites within residential areas. Limited infilling will be acceptable if it corresponds to the existing street pattern and density of the locality or on larger sites if it is comprehensively planned to make best use of previously developed land.
We will encourage an appropriate level of residential intensification within town centre areas, where higher density schemes (60+ dwellings per hectare) may be appropriate. The remaining housing requirement will be met through the allocation of land on the edge of existing settlements as outlined in H2.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.
Object
Core Strategy Preferred Options (Revised October 2008)
H2 General Locations and Phasing - Preferred Option
Representation ID: 4293
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
Rawreth should be identified as forming part of the proposed growth area to the west of Rayleigh. Where opportunities exist for developing previously developed land exist these should take precedence over greenfield housing allocations, subject to sites being available and deliverable.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.
Object
Core Strategy Preferred Options (Revised October 2008)
H3 General Locations Post-2021 - Preferred Option
Representation ID: 4294
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
Rawreth should be identified as forming part of the proposed growth area to the west of Rayleigh. Where opportunities exist for developing previously developed land these should take precedence over greenfield housing allocations, subject to sites being available and deliverable.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.
Object
Core Strategy Preferred Options (Revised October 2008)
GB1 Green Belt Protection - Preferred Option
Representation ID: 4295
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
We will seek to direct development away from the Green Belt, minimise the reallocation of Green Belt land and will prioritise the protection of Green Belt land based on how well the land helps achieve the purposes of the Green Belt. We will consider the scope for redevelopment of previously developed land within the Green Belt ahead of releasing greenfield sites within the Green Belt achieve the purposes of the Green Belt.
The need to prevent the coalescence of individual settlements, in order to help preserve their identities, will be given particular consideration.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.
Object
Core Strategy Preferred Options (Revised October 2008)
GB2 Rural Diversification and Recreational Uses - Preferred Option
Representation ID: 4296
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
We will continue our restrictive approach to development within the Green Belt, but with some relaxation for rural diversitifcation. Forms of rural diversitifaction that will be considered acceptable in appropriate circumstances in the Green Belt include:
. Conversion of existing buildings for appropriate employment use, particularly on larger previously developed sites that are able to contribute to sustainable job creation
. Green tourism (crossed out/deleted)
. Outdoor recreation and leisure activities
. Conversion of buildings to bed and breakfasts/hotels
In considering proposals for the above, issues pertaining to the purposes of the Green Belt and wider sustainability issues will be considered, but we will make allowances for the fact that public transport is limited within rural areas of the District. Proposals for retail (with the exception of farm shops) and residential development will be considered acceptable only where the site is poor in assessment of the Green Belt objectives or acceptable forms of rural diversification in the Green Belt including previously developed land.
The Green Belt provides leisure opportunities for the District, and we will allow development that contributes towards or provides facilities for outdoor sport and recreation activities considered appropriate in the Green Belt, eg changing rooms connected with a sports use. Such essential facilities will be expected to have a minimal impact on the openness of the Green Belt and contribute towards achieving sustainable communities.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.
Object
Core Strategy Preferred Options (Revised October 2008)
ED2 Employment Growth - Preferred Option
Representation ID: 4297
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
We will encourage development that enables the economy to diversity and modernise through the growth of existing businesses and the creation of new enterprises providing high value employment, having regard to environmental issues and residential amenity.
We will ensure our Economic Development Strategy and planning policies are linked, and that planning enables the spatial aspects of the Economic Development Strategy.
The provision of office space within Rayleigh town centre will be encouraged. Area Action Plans for Rochford and Hockley town centres will seek to achieve economic, as well as social and environmental benefits.
We will enhance and protect the role of small and medium sized commercial enterprises within the District's economy, including rural businesses, including appropriate previously developed sites within the Green Belt.
Policy ED2 should not discount the provision of alternative sites that would make use of previously developed land and could contribute towards sustainable employment opportunities, provided they would meet the general aims of policy ED4 as part of a mixed use development or for employment uses.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.
Object
Core Strategy Preferred Options (Revised October 2008)
ED4 Future Employment Allocations - Preferred Options
Representation ID: 4298
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
We wil allocate land to accommodate sites suitable for employment use, principally including that to the south of London Road, Rayleigh to accommodate a new employment part. We will work with partners to secure its delivery. Sites will have the following characteristics:
. able to accommodate employment uses displaced by residential redevelopment, as appropriate
. suitable for high-quality of office and industrial development
. providing a versatile layout and design that can accommodate a range of uses and can be adapted to meet changes in the economy
. accessible by a range of transport options
. benefiting from good links to the A130 and A127 and
. making best use of previously developed land.
We will also encourage the development of employment generating use within or on the edge of existing settlements, particularly town centres, where appropriate.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.
Object
Core Strategy Preferred Options (Revised October 2008)
T7 Parking Standards - Preferred Option
Representation ID: 4299
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
Parking standards should confirm with PPG13 and not expressed as minimum values. Alternative and sustainable transport options including cycleway and public transport options could justify a lower parking standard and promote sustainable transport options.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.
